State v. Williams
2012 UT App 128
| Utah Ct. App. | 2012Background
- Joshua Williams was convicted of aggravated kidnapping, a first degree felony, in Utah.
- Williams moved for a new trial under Utah Rules of Criminal Procedure 24, alleging prejudice from joint trial with a codefendant.
- The trial court found the victim credible and Williams more implicated than the codefendant, and noted Williams had a full opportunity to cross-examine witnesses and elected not to testify.
- Williams did not timely move to sever his trial from the codefendant, thus waiving severance rights under Utah law.
- The court concluded joinder did not prejudice Williams and denied the motion for a new trial, addressing both prejudice and effectiveness of counsel claims.
- On appeal, Williams challenged the joinder, arguing the codefendant’s counsel’s closing argument shifted blame to him and that the codefendant’s lesser conviction showed prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did joinder prejudice Williams | Williams argues joint trial unfairly biased the jury against him. | State contends no prejudice from joinder given defenses were not irreconcilable. | No reversible prejudice; joinder not improper. |
| Was severance required by waiver and statute | Williams contends severance was necessary due to prejudice from joint trial. | Waiver because motion to sever wasn't timely; statute permits severance when prejudice shown. | Waiver applies; no clear abuse in denying severance. |
| Did codefendant's counsel’s closing argument create irreconcilable defenses | Counsel’s blame-shifting and antagonistic stance prejudiced Williams. | Defenses were not irreconcilable; joint trial acceptable. | Defenses not mutually exclusive; no abuse in denying severance. |
Key Cases Cited
- State v. Menzies, 845 P.2d 220 (Utah 1992) (new-trial discretion reviewed for abuse; substantial adverse effect required)
- State v. O’Brien, 721 P.2d 896 (Utah 1986) (severance required when prejudice exists; hostility alone insufficient)
- State v. Telford, 940 P.2d 522 (Utah Ct. App. 1997) (mutually exclusive defenses may require severance)
- Archuleta v. Galetka, 2011 UT 73 (Utah) (ineffective assistance claim requires showing prejudice from trial strategy)